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    <title>2024 (11) TMI 353 - ITAT BANGALORE</title>
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    <description>Reassessment notice under section 148 was treated as valid because limitation under section 149 was satisfied by issuance on 28.03.2018; later service on 02.04.2018 did not invalidate it. The moratorium-based challenge under the Insolvency and Bankruptcy Code also failed, as the moratorium order had been set aside in insolvency appellate proceedings and no prior intimation to the assessing officer was shown. On the quantum issues, additions based on bank-submitted financial statements required further examination, so the merits dispute was restored for de novo adjudication after giving the assessee an opportunity to substantiate its case.</description>
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      <description>Reassessment notice under section 148 was treated as valid because limitation under section 149 was satisfied by issuance on 28.03.2018; later service on 02.04.2018 did not invalidate it. The moratorium-based challenge under the Insolvency and Bankruptcy Code also failed, as the moratorium order had been set aside in insolvency appellate proceedings and no prior intimation to the assessing officer was shown. On the quantum issues, additions based on bank-submitted financial statements required further examination, so the merits dispute was restored for de novo adjudication after giving the assessee an opportunity to substantiate its case.</description>
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